IR 05000482/2009001
| ML090630773 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/04/2009 |
| From: | Chamberlain D D NRC/RGN-IV/DRP |
| To: | Muench R A Wolf Creek |
| References | |
| IR-09-001 | |
| Download: ML090630773 (9) | |
Text
March 4, 2009
Rick A. Muench, President and Chief Executive Officer
Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
SUBJECT: ANNUAL ASSESSMENT LETTER - WOLF CREEK GENERATING STATION (NRC INSPECTION REPORT 05000482/2009001)
Dear Mr. Muench:
On February 11, 2009, the NRC staff completed its performance review of the Wolf Creek Generating Station. Our technical staff reviewed performance indicators for the most recent quarter and inspection results for the period from January 1 through December 31, 2008. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only - Security-Related Information" will include the security cornerstone review and resultant inspection plan.
Overall, the Wolf Creek Generating Station operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response column of the NRC
=s Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all performance indicators indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct reactor oversight process baseline inspections at your facility.
Our mid-cycle assessment letter dated September 2, 2008, identified a substantive cross-cutting issue in the area of human performance associated with instances of failure to have complete, accurate, and up-to-date documentation, procedures, and/or work packages within the resources component H.2(c). The basis for identifying the substantive cross-cutting issue at that time was five findings which composed a theme. During this assessment period, the number of findings increased to six findings related to the theme of failure to have complete, accurate, and up-to-date documentation, procedures, and/or work packages. These findings affected the Initiating Events, Mitigating Systems, and the Pubic Radiation Safety cornerstones. Examples include: an inadequate surveillance procedure that did not include all emergency core cooling vent valves, a procedure that did not include acceptance criteria for gaps in the containment sump, an inadequate procedure that resulted in the loss of all condensate pumps and a subsequent reactor trip, and an inadequate switchyard maintenance procedure that lead to a loss of all offsite power. During a public meeting with the NRC on October 21, 2008, you Wolf Creek Nuclear Operating Corp - 2 - informed us that you had recently completed a root cause analysis of your human performance issues. You also provided details on your Human Performance Initiative Plan and your Maintenance Work Package Quality Initiative Plan, which you were using to address human performance issues. The actions that you implemented have not yet proven effective in substantially mitigating this cross-cutting theme as evidenced by the number of existing findings related to the theme. As a result, this substantive cross-cutting issue will remain open until we determine, through our inspections, that corrective actions implemented in accordance with your improvement plan have resulted in sustained improved performance.
Also, our September 2, 2008, mid-cycle assessment letter identified a substantive cross-cutting issue in the area of problem identification and resolution associated with the corrective action program component. Three themes were identified within the corrective action program component for (1) a low enough threshold for identifying problems [P.1 (a)], (2) thoroughness of problem evaluation P.1(c), and (3) appropriateness of corrective actions [P.1 (d)] as the basis for the substantive cross-cutting issue. During this assessment, the substantive cross-cutting issue will remain open in all three areas.
First, at the 2008 mid-cycle assessment, a theme for an inadequate threshold for identifying problems was identified as part of a substantive cross-cutting issue in problem identification and resolution. At that time, there were five issues related to this theme. The theme had been identified at the 2007 annual assessment, but no substantive cross-cutting issue was identified because the issue had recently been identified to you and you had not had time to develop corrective action. In our 2008 mid-cycle assessment letter, we stated that this substantive cross-cutting issue would remain open until we determined that your corrective actions had
been effective. During a public meeting with the NRC on October 21, 2008, you informed us that you had taken corrective action which had resulted in an increase in the number of items entered into you corrective action program. We noted this specific improvement by observing that during this assessment period, there was only one finding related to the theme of failure to have an adequate threshold for identifying problems. However, we also observed that there were over 30 NRC identified findings in this assessment period. Ev en though your staff is identifying more issues, your actions have not proven effective based on the large number of NRC identified findings during this assessment peri od. Therefore the substantive cross-cutting theme associated with a low enough threshold for identifying problems will remain open.
Next, at the 2008 mid-cycle assessment, a theme associated with the thoroughness of problem evaluation was also identified as part of a substantive cross-cutting issue in problem identification and resolution based on seven related findings. During this assessment period, there were eight findings related to the theme of failing to completely evaluate problems, all in the Mitigating Systems cornerstone. Examples include: failing to ensure submerged safety-related 4160 volt cables were qualified for service, improper evaluation of mechanical agitation of a check valve, improper use of a calculation to justify the operability of emergency core cooling systems containing voids, and failure to perform an adequate acceptance review of a vendor containment sump calculation. In our 2 008 mid-cycle assessment letter, we stated that this new substantive cross-cutting issue would remain open until we determined that your
corrective actions had been effective.
During a public meeting with the NRC on October 21, 2008, you informed us that you had completed a root cause analysis for noted deficiencies related to problem identification and resolution. You informed us that you had implemented a management review program of all condition reports and established an Engineering Standards Team as part of your corrective actions for this theme. We did not observe improvement during this annual assessment period, based on the continued high
Wolf Creek Nuclear Operating Corp - 3 - number of findings related to the theme. Therefore, the substantive cross-cutting theme associated with the thoroughness of problem evaluation will remain open.
Finally, at the 2008 mid-cycle assessment, a theme associated with the appropriateness of corrective actions was also identified as part of a substantive cross-cutting issue in problem identification and resolution based on seven related findings. During this assessment period, there were eight findings related to the theme of failing to employ effective corrective actions which affected the Mitigating Systems and Barrier Integrity cornerstones. Examples include:
ineffective corrective actions for a previously identified inadequate joint which leaked during a water hammer event, ineffective actions for manual valve stem friction which allowed unplanned transfer of water from the spent fuel pool, corrective actions which did not address the missed performance of an operability evaluation for a safety-related system, and failure to take corrective actions which addressed a failure to follow procedures and take compensatory action during a loss of annunciator event. In our 2008 mid-cycle assessment letter, we stated that this new substantive cross-cutting issue would remain open until we determined that your corrective actions had been effective. During a public me eting with the NRC on October 21, 2008, you informed us that you had completed a root cause analysis for noted deficiencies related to problem identification and resolution. You informed us that you had conducted training for site leadership on their role in the corrective action process and planned additional training for root cause evaluators as part of your corrective actions for this theme. We did not observe improvement during this annual assessment period, based on the continued high number of findings related to the theme. Therefore, the substantive cross-cutting theme associated with the appropriateness of corrective actions will remain open.
As a result, this substantive cross-cutting issue in problem identification and resolution will remain open until we determine, through our inspections, that corrective actions implemented in accordance with your improvement plan have resulted in sustained improved performance.
Since this is the second consecutive assessment letter identifying the same cross-cutting issues in problem identification and resolution and human performance, we request that you provide a response to these issues at the annual public meeting. We also ask that you provide a written response to these issues and also schedule a separate public meeting to discuss these issues.
Your response should provide details on your corrective actions planned to address the cross-cutting theme including schedule, milestones, and performance monitoring metrics.
The enclosed inspection plan details the inspections, less those related to physical protection scheduled through June 30, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature.
The inspections in the last nine months of the inspection plan are tentative and may be revised at the mid-cycle review.
In accordance with 10 CFR 2.390 of the NRC
=s A Rules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Wolf Creek Nuclear Operating Corp - 4 - If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Vincent Gaddy of my staff at
817-860-8141 with any questions you may have regarding this letter or the inspection plan.
Sincerely,/RA/ Dwight D. Chamberlain, Director Division of Reactor Projects Docket: 50-482 License: NPF-42
Enclosure:
Wolf Creek Inspection/Activity Plan
cc w/enclosure:
Tim Sipe, Chairman Coffey County Commissioner
110 South 6th Street Burlington, KS 66839
Kimberly Robrahn Coffey County Commissioner
110 South 6th Street Burlington, KS 66839
Larry Crotts Coffey County Commissioner
110 South 6th Street Burlington, KS 66839 Bob Saueressig Coffey County Commissioner 110 South 6th Street Burlington, KS 66839
Fred Rowley, Vice Chairman Coffey County Commissioner 110 South 6th Street Burlington, KS 66839
Russel Stukey,Coffey County Emergency Preparedness 110 South 6th Street Burlington, KS 66839
Wolf Creek Nuclear Operating Corp - 5 - Randy Rogers, Sheriff Coffey County Sheriff's Dept.
110 South 6th Street Burlington, KS 66839
The Honorable Rick Raymer Mayor, City of Burlington
City Hall P.O. Box 207 Burlington, KS 66839 The Honorable Bill Freemen Mayor, City of LeRoy
713 Main Street LeRoy, KS 66857
The Honorable Mark Petterson Mayor, City of New Strawn
City Hall P.O. Box 922 New Strawn, KS 66839-0922
The Honorable Larry Kelley Mayor, City of Gridley P.O. Box 182 Gridley, KS 66852
The Honorable Craig Meader Mayor, City of Waverly P.O. Box 308 Waverly, KS 66871
The Honorable Ed Fisher Mayor, City of Lebo P.O. Box 14 Lebo, KS 66856-0014 Dave Beck
Allen County Emergency Preparedness Coordinator
Allen County Courthouse P.O. Box 433 Iola, KS 66749
Rick Frevbert Lyon County Emergency Preparedness Coordinator 425 Mechanic St.
Emporia, KS 66801
Wolf Creek Nuclear Operating Corp - 6 -
Gary Benjamin
Anderson County Emergency Preparedness Coordinator 315 Orange Street Garnett, KS 66032
Sheila Dale Osage County Emergency Manager P. O. Box 281 Lyndon, Kansas 66451 Institute of Nuclear Power Operations (INPO)
Records Center 700 Galleria Parkway SE, Suite 100 Atlanta, GA 30339 Vice President Operations/Plant Manager
Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
Jay Silberg, Esq.
Pillsbury Winthrop Shaw Pittman LLP
2300 N Street, NW Washington, DC 20037 Supervisor Licensing
Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Chief Engineer Utilities Division
Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027 Office of the Governor
State of Kansas
Topeka, KS 66612-1590
Attorney General 120 S.W. 10th Avenue, 2nd Floor
Topeka, KS 66612-1597
County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839
Wolf Creek Nuclear Operating Corp - 7 -
Chief, Radiation and Asbestos
Control Section Bureau of Air and Radiation Kansas Department of Health and Environment 1000 SW Jackson, Suite 310
Topeka, KS 66612-1366
Chief, Radiological Emergency Preparedness Section FEMA, Region VII 9221 Ward Parkway
Suite 300 Kansas City, MO 64114-3372
Wolf Creek Nuclear Operating Corp - 8 -
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Chuck.Casto@nrc.gov) DRP Director (Dwight.Chamberlain@nrc.gov) DRP Deputy Director (Anton.Vegel@nrc.goV)
DRP Director (Roy.Caniano@nrc.gov)
DRP Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Chris.Long@nrc.gov)
Branch Chief, DRP/ (Vincent.Gaddy@nrc.gov) Senior Project Engineer, DRP/ (Richard.Deese@nrc.gov) Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov)
Regional State Liaison Officer (Bill.Maier@nrc.gov) RA Secretary (Lucy.Owen@nrc.gov) DRA Secretary (Judy.Kilcrease@nrc.gov)
Branch Chief, DRS/EB1 (Thomas.Farnholtz@nrc.gov)
Branch Chief, DRS/EB2 (Neil.OKeefe@nrc.gov)
Branch Chief, DRS/PSB1 (Michael.Shannon@nrc.gov)
Branch Chief, DRS/PSB2 (Greg.Werner@nrc.gov) Branch Chief, DRS/OB (Bernard.Stapleton@nrc.gov)
OEDO RIV Coordinator, Primary (Shawn.Williams@nrc.gov)
OEDO RIV Coordinator, Backup (Eugene.Guthrie@nrc.gov)
OEDO, TRPS (Tamara.Bloomer@nrc.gov)
Deputy Director, DIRS, NRR (Frederick.Brown@nrc.gov) Director, DORL, NRR (Joseph Giitter@nrc.gov) Deputy Director, DORL, NRR (Timothy.McGinty@nrc.gov)
Chief, PLB IV, DORL, NRR (Thomas.Hiltz@nrc.gov)
NRR Project Manager (Balwant.Singal@nrc.gov)
RidsNrrDirslpab Resource@nrc.gov ROPreports.Resource@nrc.gov mortensengk@INPO.org
File located: R:\_REACTORS\EOC and Midcycle\EOC Assessment Letters\2008-dated 3-4-09 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials VGG Publicly Avail Yes No Sensitive Yes No Sens. Type Initials VGGRIV:C:DRP/B D:DRS D:DRP VGaddy RJCaniano DDChamberlain
/RA/ /RA/ /RA/ 2/23/2009 2/23/2009 2/24/2009 OFFICIAL RECORD COPY T-Telephone E-Email F-Fax Inspection / Activity Plan Page 1 of 1 02/23/2009 12:43:40 Report 22 03/01/2009
-06/30/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Wolf Creek EP1-EP EXERCISE INSPECTION 3 1 IP Exercise Evaluation 7111401 06/01/2009 06/05/2009 1 IP Emergency Action Level and Emergency Plan Changes 7111404 06/01/2009 06/05/2009 1 IP Performance Indicator Verification 71151 06/01/2009 06/05/2009 EB1-17T-50.59 & MODS 2 1 IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 07/20/2009 07/31/2009 EXAM-INITIAL EXAM 6 1 INITIAL EXAM-WC (8/2009)
X02419 07/13/2009 07/17/2009 1 INITIAL EXAM-WC (8/2009)
X02419 08/17/2009 08/21/2009 EB1-08-INSERVICE INSPECTION 2 1 IP Reactor Coolant System Dissimiliar Metal Butt Welds 2515/172 10/10/2009 11/06/2009 1 IP Inservice Inspection Activities - PWR 7111108P 10/10/2009 11/06/2009 RP-ORS3-OCCUPATIONAL RADIATION SAFETY - ALARA 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 10/19/2009 10/23/2009 1 IP A LARA Planning and Controls 7112102 10/19/2009 10/23/2009 1 IP Performance Indicator Verification 71151 10/19/2009 10/23/2009 RP-ORS4-OCCUPATIONAL RADIATION SAFETY - ACCESS 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 10/26/2009 10/30/2009 1 IP A LARA Planning and Controls 7112102 10/26/2009 10/30/2009 1 IP Performance Indicator Verification 71151 10/26/2009 10/30/2009 EP-1-BIENNIAL EP PROGRAM INSPECTION 1 1 IP A lert and Notification System Testing 7111402 06/21/2010 06/25/2010 1 IP Emergency Response Organization Augmentation Testing 7111403 06/21/2010 06/25/2010 1 IP Emergency Action Level and Emergency Plan Changes 7111404 06/21/2010 06/25/2010 1 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 06/21/2010 06/25/2010 1 IP Drill/Exercise Performance 71151-EP01 06/21/2010 06/25/2010 1 IP ERO Drill Participation 71151-EP02 06/21/2010 06/25/2010 1 IP A lert & Notification System 71151-EP03 06/21/2010 06/25/2010 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.